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Bert E. Van Voris - 23 - 17 September 2004 Supervising Engineer The RWD argues that the 2 mg/L dissolved oxygen limit for impounded wastewater in the WDRs is overly conservative, difficult to consistently achieve, and not warranted for odor control. The limit was based on technical information submitted by Musco relating to odor minimization. Comment: Most WDRs prescribe a dissolved oxygen limitation of 1 mg/L for impounded wastewater. This limitation reflects the implementation of BPTC and when achieved has proven effective in precluding the generation of objectionable odors perceivable beyond the boundaries of wastewater treatment and storage areas. The RWD proposes to monitor the reservoir discharge continuously for pH, EC and flow, and monthly for BOD, nitrogen compounds, IDS, TDS, sodium, and chloride. It proposes to monitor the discharge to the pond continuously for pH, EC, and flow, and weekly for BOD. Comment: To evaluate treatment performance, wastewater treatment plant influent and effluent should be monitored continuously for pH and EC and at least weekly for BOD, TDS, IDS, sodium, and chloride. Once sufficient operational data has been collected confirming that treatment performance is optimized, frequencies may be reduced for monitoring BOD, TDS, IDS, sodium, and chloride. The RWD proposes to monitor the flow and quality of seepage above the reservoir and the blanket drain for inorganic and organic constituents. It indicates that it is not practical to continuously monitor the blanket drain discharge flow. Continent: Until the issue of reservoir containment is resolved(preferably via a tracer dye study) or determined unnecessary due to the treatment of all wastewater to at least secondary standards prior to reservoir discharge, Musco should capture and return the blanket drain discharge to the reservoir. Once the piping for this is complete, installation of a continuous flow meter to measure this discharge should be practicable. Alternatively, this flow could be measured by other means at a sufficient frequency(e.g., at least weekly until data shows the proposed monthly frequency is sufficient). The RWD proposes to monitor the land application area in a manner more-or-less similar to that required by the MRP, eliminate storm water monitoring as currently performed pursuant to the MRP, and to monitor storm water in accordance with the NPDES General Permit No. CAS000001. Comment: Musco should continue to provide the Regional Board via e-mail, photographs of active application fields. It should report all future soil amendment applications and the rates at which these amendments were applied. It should continue to monitor storm water pursuant to the MRP, as this monitoring pertains to storm water runoff from application fields, not the facility itself. Endnotes 1 RWD Technical Report, p. 60, Section 9.3, 2"d paragraph 2 Ibid, p. 31, 1"paragraph.